Williams v. the State
328 Ga. App. 876
| Ga. Ct. App. | 2014Background
- Anthony Williams was convicted of burglary after a jury trial in Georgia.
- Curry testified that Williams was inside his home during the burglary and identified him; items were left behind suggesting a burglary in progress.
- Williams and Devan Williams were charged; Devan was nolle prossed for the other suspect.
- The trial court excluded Curry’s Cocaine possession conviction from impeachment as too prejudicial.
- During trial, palm-print evidence was discussed; prosecution disclosed issues with the palm print discovery after trial, argued to have not incriminated Williams.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Curry’s prior cocaine conviction | Williams; admissibility under OCGA 24-6-609 | State; defense impeachment value outweighed by prejudice | Trial court erred by not applying OCGA 24-4-403; error harmless overall |
| Prosecutorial misconduct for discovery failure regarding palm print | Prosecutor failed to disclose palm print information prejudicing Williams | Disclosures were not prejudicial since print did not implicate Williams | No reversible error; defendant not harmed by disclosure issue |
Key Cases Cited
- Martinez v. State, 306 Ga. App. 512 (2010) (evidentiary balancing under Rule 403 and prior conviction impeachment)
- Kimbrough v. State, 254 Ga. 504 (1985) (impeachment via prior conviction requires proper foundation; conviction proofed by record)
- Hoffler v. State, 292 Ga. 537 (2013) (harmless-error analysis for evidentiary rulings)
- Kitchens v. State, 289 Ga. 242 (2011) (harmlessness of prosecutorial misconduct when no prejudice shown)
- McGarvey v. State, 186 Ga. App. 562 (1988) (misconduct not requiring dismissal absent demonstrable prejudice)
- Brooks v. State, 285 Ga. 246 (2009) (general standard for evaluating prosecutorial misconduct)
- Martinez v. State, 284 Ga. 138 (2008) (impeachment standards for prior misconduct; admissibility)